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#2271722 - 06/15/22 07:46 PM Force placed hazard insurance
MCCompliance Offline
100 Club
Joined: Nov 2012
Posts: 102
Borrower's hazard insurance policy has lapsed. We sent the 45 day letter advising that we have force placed the insurance. In conversation with the borrower, borrower wants to keep the force placed insurance policy rather than obtaining their own policy. The borrower asks the bank to debit his checking account for the premium. Since we just sent the 45 day letter, we have not made it far enough to send the 15 day reminder letter.

Are we able to accept the payment from the borrower now, or do we need to wait until day 46? We did not request payment from the borrower.

Thanks in advance.
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RESPA
#2271727 - 06/15/22 08:29 PM Re: Force placed hazard insurance MCCompliance
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
Tough call. You have to meet the requirements before charging the borrower. There is no mention of the borrower voluntarily paying before that time. IMHO - If you have not charged them yet - there is no bill for them to pay.
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